Implementation of the OECD minimum tax rate in Switzerland

Switzerland introduced the OECD minimum tax rate on 1 January 2024. What are the implications of implementing the minimum tax rate for the Federal Constitution, the tax system, the federal budget and the companies affected?

Brief summary

The OECD minimum tax rate will be implemented in Switzerland by means of an ordinance. The people and cantons approved the necessary constitutional amendment in a popular vote on 18 June 2023. During its meeting on 22 December 2023, the Federal Council decided to implement the minimum tax rate with the introduction of a supplementary tax in Switzerland from 1 January 2024. It will thereby prevent the erosion of the Swiss tax base in favour of other countries and create stable framework conditions. It will decide on the introduction of the international supplementary taxes by the end of 2024. Within six years, the Federal Council must additionally submit to Parliament a federal act that replaces the ordinance.


The existing taxation of large multinational enterprises is no longer appropriate in the view of the Organisation for Economic Co-operation and Development (OECD) and the Group of Twenty major developed and emerging economies (G20).

In October 2021, over 140 countries, including Switzerland, agreed that large multinational enterprises with turnover of EUR 750 million or more should pay at least 15% tax on their profits.

The vast majority of EU member states and other important industrialised nations intend to implement the minimum tax rate as early as 2024. If Switzerland were to refrain from introducing the minimum tax rate, the Swiss arms of corporate groups from these jurisdictions would be taxed more heavily by their parent country, which would lead to base erosion in favour of other countries.

Constitutional amendment

On 18 June 2023, 78.5% of the electorate approved a constitutional amendment that creates the legal basis for implementing the minimum tax rate in Switzerland. One of the aims of the proposal's authors was to ensure that the receipts from higher taxation remain in Switzerland and do not flow abroad.

A transitional provision in the Constitution provides the Federal Council with guidelines on how it should implement the minimum tax rate. The Federal Council has issued an ordinance for this purpose. It will remain in force until it is replaced by a federal act. The Federal Council must submit this federal act to Parliament after six years at the latest.

Those concerned

Only large multinational enterprises with global annual turnover of at least EUR 750 million are subject to the new minimum tax rate. In Switzerland, this concerns a few hundred domestic and a few thousand foreign corporate groups. Thus, approximately 99% of companies in Switzerland are not directly affected by the reform and will continue to be taxed as before.

Taxation may turn out to be lower than 15% in all cantons. However, cantons with a low tax burden, where many large and profitable companies are based, will be particularly affected.

Supplementary tax in the ordinance

If the minimum tax rate is not reached, the shortfall will be levied by means of a supplementary tax. The supplementary tax is a federal tax. As with direct federal tax, it will be assessed by the cantons.


The financial impact of this minimum tax rate is unclear. The receipts from the supplementary tax are initially estimated to be roughly CHF 1 to 2.5 billion. One reason for the uncertainty when estimating is the limited pool of data. In addition, the assessment base in accordance with the OECD/G20 differs from that under Swiss law. Moreover, the estimate does not take account of potential behavioural adjustments by companies (e.g. in the form of lower investments in Switzerland) and tax policy decisions by the cantons (e.g. changes to profit tax rates).

The OECD/G20 project makes Switzerland less appealing from a tax perspective. Any ensuing adjustments made by companies in the medium to long term could adversely affect the receipts from almost all taxes and also those from social security contributions. Consequently, some of the funds collected with the supplementary tax should be used to finance measures that benefit Switzerland as a business location. Tax competition within Switzerland will also tend to be slightly restricted. High-tax cantons will become more attractive relative to low-tax cantons. The administrative burden for companies and authorities will likewise increase.

Q&A on the implementation of the OECD/G20 minimum tax rate in Switzerland


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Last modification 14.02.2024

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